Facebook Ad Transparency – Pharma Implications

Senior Director, Social Media

Facebook is working hard to improve its public reputation regarding ads on the platform in the aftermath of the Russian political interference scandal. This work has centered on how to give the audience the tools needed to determine whether or not to trust the information being promoted to them.

UPDATE: we have been working closely with Facebook to better understand these changes. Some updates to the Canadian Ads description are included below.

For the first time as a species, humans live in a world where information is abundant. The history of human civilization is very much one of political and physical expansion shaped by the available communication technology as detailed in Harold Innis’ “Empire and Communications.” From the clay tablets of the Sumerians that allowed for commerce to the papyrus scrolls of the Romans that allowed their empire to grow communication technologies have always influenced how we live.

Now we’re no longer worried about clay or papyrus, our medium is the internet and it has democratized the way we communicate. This hand-off of information control from the gatekeepers of the past to the general population has had some unintended side effects. Now the minority voices can be more easily found and heard and this has helped many groups advocate for their issues but it has also enabled fringe groups to do the same (everyone’s definition of “minority” and “fringe” varies but all will probably agree there is a spectrum).

One issue that has come to light is the organized and financially funded promotion of misinformation online, especially from Russia. These campaigns of politically-charged ads have been the subject of FBI, DOJ, and Congressional investigation. All of the major internet networks – Facebook, Google, Twitter, and others – have been investigating their systems for evidence of illegal use and have been disclosing what they find to the investigators.

Facebook is the first platform to really sink its teeth into the problem and come up with solutions. The company has already hired 1,000 more ad reviewers to manage the system but it is also changing its core system to give users the opportunity to see for themselves what Facebook advertisers are up to. There are three elements of these changes that will matter to pharma marketers and while may impact how brands work with their regulatory groups.

Increased Enforcement

With the increased enforcement there may be worry that more ads will be rejected or have their reach limited. This worry seems to be unfounded because well-crafted pharma ads have a long track record of effective Facebook use. All current Facebook campaigns that are managed by pharma-experienced agencies follow the important rules:

Cannot imply that the user has a particular health condition

Cannot target users based on liking 3rd party pages

Must tell user to talk to their doctor (cannot promote sale of drug)

All well-run pharma campaigns already follow these rules plus all the non-pharma ones such as the infamous 20% text rule.

Ad Information Icon

An upcoming change that will most certainly matter to brand marketers and their regulatory groups is the addition of the Information button to Facebook ads. This change was announced October 7 and will be adding information to users’ views of ads. Current information is that the information will be gathered from either the Facebook Page and/or Wikipedia. The source of the information will be of utmost importance to the regulatory teams and the FDA in interpreting who “owns” it and therefore who is responsible for it.

The Information Button

Once these updates are complete, with rollout scheduled for Q1 2018, users will be able to review background information about an ad. We don’t have a lot of detail, but based on the Oct 7 post from Facebook it looks like the content will come from a combination of:

How the audience will be able to get more information on Facebook sponsored posts

How to Present this Change

Context can make all the difference for conversations like this. Brand marketers should approach their regulatory groups ASAP so that the groups can prepare for this change. Some points we would suggest for those meetings are:

Ensure there is a social expert in the room so that most questions can be answered immediately with as little follow up as possible because that will instill confidence that the team knows what’s going on with these changes.

Highlight that the content being displayed is out of the Page’s control and, just like other unrelated content on Facebook, should not be considered as part of any submission to the FDA.

Inform the teams that these changes are scheduled for Q1 2018 and ensure you have close ties with your Facebook rep to ensure you keep abreast of changes to the format and release date.

Page Ads List

Next on the Facebook change dossier is ads being shown on pages even when they are “hidden.” This functionality is already released in Canada so we were able to look at the system running and give brands a preview of what will be hitting in Q1 2018.

Essentially, the new “Ads” button will show all active ads that are targeted to the viewer’s location. So, for right now we can’t use this feature to see US-targeted ads on Pages that are visible from Canada. For pharma brand marketers this feature won’t cause any real trouble because the buttoned-down nature of the industry means all active ads will be acceptable. [Updated June 21, 2018]One note for regulatory conversations is that Facebook is planning on showing historical ads in the future.Even for ads that are deleted the old versions may be still available, however like magazine ads this shouldn’t cause any real trouble because the brand is not in control of this functionality. Only active ads at the time of review will show to the user – old ads do not appear, and geoblocked pages will not show for users outside of the specified locations so regulatory groups really should not have any concerns once they see how the list works. However, the word “should” can be difficult here so make sure to talk to your regulatory group earlier rather than later.

Here is an example of two health pages in Canada that have active ads running:

Ads list from two Canadian pages with active ads running

Summary

Changes are coming to Facebook that may spark some discussions between brand managers and regulatory but overall Facebook promotion should remain stable. These changes should be viewed as good for pharma marketers because anything that helps with trust on these social platforms will increase the value of legitimate ads while reducing the noise from “fake news.”